Speaking in New York at the Global Anti-Corruption, Ethics and Compliance Conference on 3 June 2026, Director of the Serious Fraud Office Graham McNulty set out the organisation’s priorities and ambitions.
These focuses across three areas, the SFO’s commitment to working with responsible corporates, its plans to become a more active enforcer, and its role as a leading player in the international justice system.
The speech highlighted the SFO’s revised corporate cooperation guidance, the recently agreed Deferred Prosecution Agreement with Ultra Electronics, and plans to strengthen intelligence capabilities, increase the use of surveillance, and incentivise whistleblowers.
The Director also underlined the SFO’s close working relationships with international partners, including the US Department of Justice and the newly established anti-corruption prosecutorial taskforce with France and Switzerland.
Read the full text below.
It’s a real privilege to have the opportunity to speak at the Global Anti-Corruption, Ethics and Compliance Conference here in New York.
It’s just over a month since His Majesty The King was here.
That state visit was a reminder that the United Kingdom and the United States are bound not only by history but by a shared commitment to the rule of law.
For those of us in law enforcement, that commitment is operational corruption, fraud and illicit finance move seamlessly across jurisdictions and so must our response.
I am approaching my 35th year in law enforcement and I can look back over decades of co-operation with a plethora of US law enforcement agencies, who have always come to my aid, shared intelligence, evidence and friendship to get difficult and sometimes dangerous operations over the line.
I cannot name them all but my particular thanks go to the FBI, Homeland Security, the DEA and of course the Department of Justice.
Our nations on either side of the Atlantic have benefited from these shared endeavours to keep people safe, seize weapons, drugs and cash, and put behind bars those who would bring chaos and misery to our neighbourhoods.
I have been fortunate over the years to receive awards for a variety of operations. My wife has never been keen on me cluttering the house with these but the one I do have on display above the mantlepiece is an award presented to me in the US Embassy in London upon my retirement from policing. The inscription is about being a ‘dedicated partner’ in the fight against crime.
So you will understand why I am so pleased to be here in the US at this event – it does feel like my second home.
Before becoming the Interim Director of the Serious Fraud Office, I spent 18 months as its Chief Operating Officer, and prior to that, 31 years in policing, mainly at New Scotland Yard.
I think it’s important to be honest about the things I am not. I am not a lawyer, I am not a compliance expert. At heart, I am a cop who spent most of his time tackling serious and organised crime which in my era has meant international collaboration is not a luxury but an absolute necessity.
Working in the SFO has made me reflect on my policing career. Whilst in policing, I had to deal with a lot of hardened criminals who did some horrific things. When I reflect on those individuals (and I am not making any excuses for their crimes) many were born on the wrong side of the tracks, often into poverty, addiction and without any family to support them.
I then look at the criminals I deal with now. Many were born into a world of wealth and luxury, with a silver spoon in their mouth. There is only one thing I can see that connects them all and that is greed. A greed to make even more money, a willingness to defraud not only people but nations and a reluctance to accept any accountability for their wrongdoing.
In order to target these criminals successfully, the SFO was set up to take on cases from cradle to grave, from referral, intelligence development, through investigation to prosecution and actively looking to seize and return assets throughout that process.
Our model brings together different professionals to work side by side from the very beginning of our cases. It’s an approach which makes sense given the complexity of our work.
This was a big change for me when I joined. For years, I had been in the police and was used to working closely with the Crown Prosecution Service, but I would not generally have considered speaking to a lawyer at such an early stage of an investigation.
Since being at the SFO, I have seen the real benefit of this close working relationship right from the start.
It’s an approach that has evolved over the years. Today our teams are truly multi-disciplinary and as likely to bring together data specialists, forensic accountants and digital forensic experts as well as the more traditional lawyers and investigators that were envisaged when the SFO was established.
I am incredibly lucky to lead an organisation of dedicated, hard-working skilled professionals.
This model, our specialist staff and the powers that we are equipped with put us in a unique position to take on the most complex cases.
I’ve worked on serious and organised crime for many years and yet the complexity of the SFO’s cases goes beyond anything that I had seen before.
Virtually all our cases involve other countries. This means evidence must be sought from multiple jurisdictions, funds must be traced across the globe, and we must be adept at working in different legal environments.
We are frequently prosecuting multinational companies who can defend themselves with resources that dwarf our own. There are huge numbers of documents to analyse, with an average case having 5 million, all of which are subject to disclosure requirements.
At trial, our cases are listed for up to six months. Losses can run to tens if not hundreds of millions of pounds and there can be thousands of victims.
I was recently challenged by a senior UK legislator on why it is that our American counterparts can sometimes deliver outcomes more quickly than we can.
Helpfully, I was with a US colleague who explained that from their perspective, the UK legal framework made fast outcomes very difficult, noting our nations’ different approaches to disclosure requirements, the approval of DPAs and the length of sentences received.
You know better than most the challenges that we at the SFO face. It’s easy to be defeatist, to focus on the complexity of the investigations, the limits of resourcing and ultimately the scale of the threat.
We take on difficult and important work, and have had our setbacks, and we will always face criticism for not doing more.
Given all this, you may doubt the impact of the SFO but I know that we do make a difference and I hope to convince you that our work matters to you.
Today I want to take you through three areas that show you that the SFO is
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an ally of the responsible corporates that you represent
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a more active enforcer than ever before
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a leading player in the international justice system
And that in all of these areas, we have ambitious plans to go further.
I have just passed my fiftieth day as the Interim Director and it’s been a busy few weeks in post
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We agreed a Deferred Prosecution Agreement with the British defence supplier Ultra Electronics and I’ll speak more on that shortly.
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We, with our French and Swiss partners, brought together the world’s leading agencies for tackling bribery and corruption at a first of its kind conference. We were delighted with the relationships built, the best practice shared and the commitment of our partners, including US colleagues from a range of agencies.
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We undertook a series of dawn raids and arrested four individuals and searched six premises, as part of our investigation into alleged fraud by three companies in relation to a government energy efficiency scheme. This continues our fast pace of executive actions to progress our investigations.
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And in a couple of weeks’ time, there will be the sentencing of three individuals convicted for fraudulent trading earlier this year, in relation to a £70 million investment scheme fraud.
I am now going to talk about how the SFO is an ally of responsible businesses and I’m going to cover two things
In agreeing the DPA, the British defence supplier Ultra Electronics acknowledged accountability for failure to prevent bribery in relation to three public sector contracts sought through the use of agents.
They are required to pay a £10 million penalty and £4.8 million in SFO investigation costs.
It’s important to reflect on how we got here.
The investigation that led to this DPA was opened back in 2018 when we received a self-report from the company.
At that stage, we were looking into bids for two projects in Algeria, one for Algiers airport and the other for a government ministry.
In 2021, we invited Ultra to negotiate a DPA. In July of the following year, we were at a late stage in those negotiations when Ultra disclosed information regarding the conduct of its employees in a bid for a project for two airports in Oman.
We did not accept Ultra’s analysis of this information and we withdrew from the negotiations later that year, concluding that the conditions for a meaningful agreement were not in place. We then expanded the scope of our investigation to cover the activity in Oman.
It was only following significant changes to the company’s ownership, structure and leadership that negotiations resumed. When the corporate came forward with all the relevant information, we were able to negotiate the DPA within just eight months.
This demonstrates that how a corporate cooperates with our investigation is key to deciding how a case is resolved.
The SFO will walk away from negotiations and pursue a prosecution unless a company genuinely cooperates.
At the same time, this DPA demonstrates our pragmatism and willingness to work with responsible corporates.
I would now like to turn to our revised corporate cooperation guidance.
Let me be clear – I want the SFO to receive more self-reports, which will lead to more DPAs.
I know some of you may find yourselves advising a corporate on whether to make a self-report. In giving such advice, you will be looking for clarity about the process.
Many of you will be aware that last year we launched our revised corporate cooperation guidance which aims to give this clarity.
The guidance commits that if a corporate reports to us promptly and cooperates fully, we are offering a near-guarantee that, unless exceptional circumstances apply, we will invite them to enter negotiations for a deferred prosecution agreement.
We recognise that speed matters. Corporates don’t want to see investigations that drag on for years without resolution. That’s why, for the first time, we commit in the guidance to
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Make contact within 48 business hours of a self-report.
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Provide regular updates throughout the process.
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Make a decision on whether to open an investigation within six months of a self-report.
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Conclude our investigation within a prompt time frame.
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Conclude DPA negotiations within six months of sending an invite.
You will understand that with our duties as a prosecutor, there will rightly always be limits to the commitments that we can make.
Nevertheless, I believe that in this guidance we have challenged ourselves as an organisation to make the strongest possible offer to responsible corporates.
If you self-report wrongdoing to us and cooperate, you will find an SFO ready to work with you effectively. In doing so, we will adhere to our duty of ensuring an appropriate penalty but also that a responsible corporate is given the best possible opportunity to reform and to progress.
I now want to show you that the SFO is a more active enforcer than ever before.
I’ll be covering four areas
We are becoming more proactive and seeking to find wrongdoing ourselves. The UK government has made a multi-million pound investment into our intelligence capabilities.
We are building our own enterprise intelligence system which will better harness and aggregate data from disparate sources and, linked to our new case management system, will make it easier to identify threats by linking information across cases.
When I led the Serious and Organised Crime Command as a police officer, we never waited for referrals. We built intelligence, using both technology and human intelligence sources to identify the threats and tackle them.
Proactivity makes it possible to intervene as crimes are occurring, protect potential victims and prevent the dissipation of assets. While we will always welcome referrals, we are building a pipeline of work that will make us less dependent on them.
Not self-reporting is a gamble and the odds are getting worse.
I now turn to surveillance. When tackling crime in the toughest neighbourhoods, I made full use of the powers of the state in pursuing offenders. We were sometimes quicker to do this for a local drug dealer than for an international fraudster.
The approach to perpetrators of complex, economic crimes can be too gentlemanly with unmerited deference. A sharp suit and a high-end profession should never hide the damage done and the victims harmed.
We at the SFO, working with our law enforcement partners, can use surveillance in our investigations and I am determined to make full use of this tool.
I am also working with the government to obtain the ability to make our use of these powers more efficient so we can use them at pace in investigations and not miss crucial opportunities.
Whistleblowers are another vital source of information. I am a strong advocate for generating human intelligence and I support a whistleblower incentivisation scheme for the SFO.
One of my previous roles was the UK policing lead for Covert Human Intelligence Sources, known as CHIS in the UK or as informants. I believe the development of new technologies has in some respects pushed what is the oldest intelligence source in the book off the agenda.
I have seen this methodology used countless times in my career to recover firearms, drugs, stolen property and undoubtedly it has saved lives.
Whistleblowers are different to CHIS but the core principle remains the same. Having somebody on the inside who can tell you
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What happened
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When it happened
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Who was involved, and crucially
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Where you need to look to recover the evidence
When you reflect on the type of cases the SFO investigates, this has the potential to
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Take years off an investigation
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Avoid collateral intrusion by placing far tighter parameters on an investigation
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Allow the SFO to take on many more cases
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Free up court time
We have seen the effectiveness of incentivisation with our US law enforcement partners.
UK whistleblowers are the second biggest users of American incentivisation programmes, with over 700 UK nationals making an active choice to provide intelligence to the four US programmes between 2012-2023.
That represents a significant intelligence outflow from the UK that I do not believe would be tolerated with other crime types.
We welcome the UK Government’s decision to ask Jonathan Fisher KC to consider this in the second part of his review which is expected to be published later this year.
We await that report and hope to make progress on this important issue with our government partners.
New legislation, particularly the Economic Crime and Corporate Transparency Act, has significantly expanded the range of offending which the SFO can now take enforcement action against.
The failure to prevent fraud offence means large organisations can be held criminally liable where an associated person commits a fraud intending to benefit that organisation.
Crucially, it captures conduct committed anywhere in the world, provided there is a UK nexus.
The SFO has made clear its commitment to make full use of the new offence. Alongside prosecutions, the offence should be a prevention tool, cutting off fraud at its source and driving cultural change in the economy.
In addition, the bar for corporate criminal liability has been significantly lowered by the “Senior Manager” test which strengthens our ability to hold companies to account for wrongdoing.
I would now like to turn to the international aspects of our work.
Our bribery and corruption investigations always require effective international cooperation. We are building stronger relationships with our partners to ensure that borders do not pose barriers to enforcement.
While the harm caused to the economy and prosperity of the UK are always key considerations in deciding which cases we take on, I am clear the SFO always seeks to be a leading player in the global justice system.
We work closely with partners to determine our respective roles in an investigation. This will come down to factors including the location of evidence and offending, where the suspects are based, each country’s enforcement options and the public interest.
Effective enforcement rests on this coordination and this is best delivered when there are strong relationships in place.
I noted at the start of my speech my respect and admiration for US law enforcement and prosecutors. I’m delighted that we have such a strong and enduring relationship with our American colleagues. Their attendance at our international conference last month was a strong show of their commitment to work with us.
We receive strong support from DOJ colleagues across all the cases where we need it.
Tysen Duva, the Assistant Attorney General of the Criminal Division, clearly outlined the DOJ’s enforcement priorities this morning.
When there are cases which do not fit those priorities and have a UK nexus, we look actively at taking them on.
We have also taken a significant step forward with two of our closest European partners. Last year, we, the French PNF (Parquet National Financier) and the Swiss Office of the Attorney General (OAG), established the international anti-corruption prosecutorial taskforce.
This built on the already strong relationships that we had with these agencies and the successes that we have secured together in the past.
In forming the taskforce, we have moved beyond the model of case-by-case collaboration to a closer way of working that gives each of us an in-depth understanding of each other’s systems and puts us in the strongest possible position to take cases forward.
I am delighted that Krisztina from the Swiss OAG will be speaking on international anti-corruption enforcement tomorrow and I’m sure she’ll share her perspective on the importance of the taskforce.
An excellent example of a case built on international cooperation is our investigation into AOG Technics. This case shows the wide-reaching and unexpected harm that fraud can cause.
From 2019 to 2023, the company defrauded customers by falsifying documentation related to the origin, status or condition of over 60,000 aircraft parts.
Hundreds of planes in the UK and around the world were grounded after aviation authorities issued safety alerts to airlines that may have bought or installed AOG’s parts.
It’s very possible that people in this room flew on those planes. At the end of last year, we secured a conviction.
We had a successful JIT (Joint Investigation Team) agreement with Portuguese authorities which included invaluable cooperation on searches and arrests. We were also indebted to our French partners for the speed of their assistance which meant we received information far quicker than is typical and helped us get to a conviction at pace.
Strong partnerships deliver when it matters most. As well as all those countries I have mentioned, we are building and strengthening partnerships on every continent.
In conclusion, I believe I’ve demonstrated to you that the SFO is
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an ally of the responsible corporates that you represent
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a more active enforcer than ever before
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a leading player in the international justice system
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and we have ambitious plans to go further.
I hope you can see our relevance to your work. We are ready to work with responsible corporates who self-report wrongdoing.
Through our ambitions of proactive intelligence, incentivising whistleblowers, surveillance and the use of our new powers, we are seeking to do more than ever before to uncover and take action against wrongdoing.
And we are strengthening our partnerships to ensure that there is an international response to what is an international problem.
Corruption flourishes when people believe nobody is watching and nobody will act. Our job, working together, is to prove them wrong.
Thank you very much for your time.
